In a complaint-affidavit filed Wednesday before the Department of Justice (DOJ), Garin said Ubial violated Article 365 (Imprudence and negligence) under the Revised Penal Code.

Under Philippine law, reckless imprudence "consists in voluntary, but without malice, doing or falling to do an act from which material damage results by reason of inexcusable lack of precaution on the part of the person performing of failing to perform such act, taking into consideration his employment or occupation, degree of intelligence, physical condition and other circumstances regarding persons, time and place."

Garin said the decision of Ubial to implement a community-based dengue immunization program rather than a school-based one was seen as the "only possible cause" of the reported deaths of the children.

She added "deaths were reported soon after the implementation of Sec. Ubial's community-based program started." Ubial assumed the Health Secretary post in 2016.

The former secretary said her successor also expanded the coverage of the immunization, and also allegedly "relaxed the consent protocol" for immunization authorization— contributing to the death cases.

"It is unfortunate that several complaints were filed against me and other DOH officials when in truth only Sec. Ubial's negligence contributed to the alleged reported deaths," the complaint read.

Garin and other public health officials were slapped with criminal complaints over the controversial nationwide Dengvaxia vaccination program which started in 2016.

A study earlier this year by the Philippine General Hospital's Dengue Investigative Task Force revealed that two out of 14 deaths being linked to Dengvaxia may have been caused by the vaccine's failure, while some of the other cases were unrelated to the vaccine.

Out of the 14 deaths, experts said three died of dengue shock syndrome, including the two who may have died due to Dengvaxia failure.

The government halted the nationwide anti-dengue program in December 2017.